Virginia Regulatory Town Hall
Department of Professional and Occupational Regulation
Board for Hearing Aid Specialists and Opticians
Hearing Aid Specialists Regulations [18 VAC 80 ‑ 20]
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10/31/11  1:30 pm
Commenter: Paloma Robinson, Au.D. / Professional Hearing Services

Removing examination requirements for audiologists appyling for Hearing Aid Specialist licenses
William H Ferguson, Executive Director
Commonwealth of Virginia
Department of Professional and Occupational Regulation
Board of Hearing Aid Specialists
9960 Mayland Drive, Suite 400
Richmond, VA 23233
                                   Subject: Periodic Review of Regulations and Public Participation Guidelines for its regulations, 18 VAC 80-20, and public participation guidelines, 18 VAC 80-11
Comment: Remove the written and practicum examination requirement for Virginia licensed audiologists applying for a Virginia Hearing Aid Specialist license.
Dear Mr. Ferguson,
I am a Doctor of Audiology.  During my graduate training for my Au.D., I took 2 diagnostic testing courses, 2 amplification courses, 1 acoustics and instrumentations course, 1 pschoacoustics course, 1 anatomy course, 1 communication technology course,  several counseling courses and aural rehabilitation courses in addition to the extra research, professional issues and other courses pertinent to my field of study.  We learned the in and outs of hearing aid circuitry, programming, verification and validation.  I had 3 internship placements and a full year of what would equate to a “residency” in the medical field.  I took and passed candidacy exams in my graduate program.  I’ve been certified by ASHA as clinically competent in Audiology and I have passed a Praxis exam.
These courses and requirements are a standard that have been established by accrediting bodies to ensure that training for all Doctors of Audiology is thorough, comprehensive and all encompassing and to make certain all curriculums in this field meet and exceed certain expectations of knowledge and skill.
I take issue with having to take yet another “exam” to prove that I have the expertise in the field for which I hold a doctorate.  Additionally, the fact that an Otolaryngology physician can receive a hearing aid specialist license without any testing at all is baffling.  In my opinion we are more qualified and educated in the picking, fitting, adjusting, verifying and counseling of these devices than most if not all ENT physicians, whose medical expertise is essential in our work but does not replace our knowledge.
In addition, because both portions of the test are taken on separate days a month apart, additional burden is placed on small business with loss of revenue and additional costs for accommodations and travel expenses since many practicing audiologists live outside the Richmond area and must travel the night before to arrive at the 8 am exam.  
In short, I believe that Audiologists should be exempt from both portions of this exam. We have been thoroughly trained in the proper fitting techniques as well as the ethics side of our field.  This examination is redundant for Audiologists as the level of skill and knowledge required for Audiology licensure far surpasses that required for Hearing Aid Specialists.
Thank you for your attention.
Paloma Robinson, Au.D., CCC-A, FAAA
Professional Hearing Services
8314 Traford Lane, Springfield, VA 22152
CommentID: 21142